Eskom’s Revenue Application for Multi Year Price Determination MYPD (2)

1. Eskom’s Revenue Application for Multi Year Price Determination MYPD (2)

2. Introduction • The EIUG is the association of large energy intensive consumers in South Africa. • Membership currently consists of 38 of the largest energy consumers • That together, consume 40% of the total electricity sales in South Africa.

3. Context • Eskom needs a long term sustainable return on its capital invested, • However Eskom’s funding request of a 35% increase per year for the next three years poses a real economic threat, which will result in lower economic growth rates, lower employment growth and ultimately job losses. • This is unacceptable and, we believe, unnecessary in achieving the reliable and cost effective supply of electricity.

4. EIUG Focus • South Africa deserves and is entitled to, reliable and affordable electricity for all. • As bulk consumers the EIUG members have a vital role in the economy in stimulating bulk electricity demand on a 24 hour a day basis, 7 days a week. • This infrastructure supports cost effective and reliable supply to consumers who require less energy at particular times in the day

5. The NERSA dichotomy • It is clear that the challenge facing NERSA is the trade off between a strong electricity sector and a strong economy • The price increase needed to sustain Eskom supports neither of the above aspirations • Eskom needs a cash injection and an improvement in its operating efficiency to support a strong economy • No provision has been made for the cash injection and the increase in operational cost must be borne by the consumer • Electricity is a production input cost to all in the economy and has a significant multiplier effect

6. Key elements of the EIUG submission • South Africa needs a comprehensive Integrated Resource Plan [IRP] • The IRP in its present form is not adequate to enable NERSA to make a rational cost determination • Large power plants, be they conventional coal or nuclear require long planning horizons • Serious and urgent effort needs to be allocated to establishing the IRP • The IRP requires a funding model and plan • This plan must define how the income for feasibility studies, construction and operating costs, equity, debt and private sector investment; and the make up of the energy and technology mix for the country is optimised to make best use of our limited skills and resources for the benefit of all South Africans

7. Eskom Efficiency • Last year at the interim price increase hearings the EIUG and COM defined a number of areas where Eskom could improve on its operational efficiency, notably in the coal procurement arena. • It is recommended that Eskom be requested to deliver an improvement plan as part of these deliberations so that operating cost reductions can begin to materialise • The EIUG would support Eskom provision for expenditure in the transmission and distribution sectors but is mindful of the logistical difficulties in spending large sums of money effectively in a short time span

8. Eskom Cash Injection • The proposal for Eskom to divest part of the Kusile project is a step in the right direction, however Kusile will have limited uptake as has been discussed by many other speakers but primarily due to the fact that construction risk has already been managed by Eskom and potential bidders cannot apply their expertise to enhance their capital return • The Kusile project risk is with Eskom and the South African consumer – not so some of the older established power stations with good track records where potential investors would be keen to show their skills – if the market became encouraging for them • The current market for IPPs is considered hostile so urgent attention is required to tap into this opportunity

9. Key elements of the EIUG submission • The “country plan” • Eskom funding • Security of Supply • Limiting job losses • The long term price cone • Non core issues

10. The “Country Plan” • The development of a country plan [in the form of an IRP] is urgent and will present some short term options allowing for a more manageable roll out of the long term build program • The appropriate legal and regulatory framework to convert SA from an IPP hostile environment to facilitate the introduction of IPPs must be urgently introduced

11. Eskom Funding • A revision of the Eskom funding model is urgently required • Eskom estimates need challenging: • Cost of capital • Asset value and valuation methodology • Depreciation • Primary energy and operating costs • Capital expenditure • Medupi and Kusile are too expensive and late

12. Security of Supply • One factor that has reduced the price increase from 45% to 35% is by reducing the RSA forecast demand based largely on an aggressive DSM uptake • However past uptake has been low and the increased uptake is not supported by a change in DSM management • Similarly the mass role out of solar water heaters is both financially and operationally constrained

13. Limiting Job Losses • It is imperative that there is adequate and affordable electricity capacity to promote economic growth and that our price leadership role in this arena is not lost • Eskom has conceded that it is not in a position to meet all future demand, • Hence the integrated roll of IPPs is critical by • Development of an appropriate legal, regulatory and commercial framework to facilitate IPPs

14. The Long Term Price Cone • This needs to be reduced by: • Reducing Eskom return on investment • Managing and reducing the new build cost • Alternate funding including sale of assets • Accelerating the pace of IPPs • Decreasing Eskom’s operating expense inflation • Bringing Eskom’s operating efficiencies under control

15. Non core Issues • Eskom has removed some expenditure on non core assets however it is not clear that this responsibility has been accepted by counter parties [e.g. road maintenance]

16. Thank You